ML19325E111
| ML19325E111 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 10/27/1989 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8911020004 | |
| Download: ML19325E111 (5) | |
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David W. Cockfield Vice President, Nuclear
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P October 27, 1989 Trojan Nuclear Plant l
Docket 50-344 License NPF-1 i
U.S. Nuclear Regulatory Comission
' ATTN: Document Control Desk Washington DC 20555
Dear Sir:
~ I Additional Information Pertaining to Inspection Report 50-344/89-09' Your letter of August 29 't989 forwarded Inspection Report 50-344/89-09.
There were several requests for additional information contained in the
, body of the report.
Attachment I to this letter provides the requested Information.
t sincerely,
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Attachment c:
Mr. John B. Martin Re5 onal Administrator, Re5 on V c
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U.S. Nuclear Re5ulatory Comission Mr. David Stewart-Smith State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant i
8911020004 891027
' l gDR ADOCK 05000344
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Trojan Nuclear Plant Document Control Desk l
Docket 50-344 October 27, 1989 l
License NPF-1 j
Page 1 of 4 l
RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION 1.
Weaknesses in the Identification of Visually Apparent Deslan Problems A walkdown of the emergency ventilation. system for-the Control Room, CB-1, resulted in identification of an improperly installed venti--
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lation support by.the inspector. The inspector requested Portland l
General Electric (pCE) Company to determine if this condition had been previously noted and evaluated. POE responded it had not..'At a meeting with PGE on June 8, 1989, the inspector questioned management regarding the programs in place that should identify deficient conditions which could affect proper design basis implementation.-
Several additional' examples of problem identification deficiencies were noted by the Nuclear Regulatory Commission (NRC) team during the inspection. As a result of this observation and discussion, PGE management committed to address needed' actions to increase the recognition and evaluation'of visually apparent problems'in response ~
to the inspection report.
Response
In 1989, PGE has generated over 450. Nonconforming' Activity Reports
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(NCARs), 500 Nonconfomance Reports (NCRS) and 10,000 Maintenance l
Requests. These problem identification and tracking systems show that PGE has recognized and taken-actions to evaluate visual, as well as administrative, problems at Trojan. PGE will~ continue to emphasize problem identification and resolution to'. ensure all I
apparent problems are identified and appropriate corrective action is l
taken.
1 one such mechanism to identify apparent problems is the walkdowns of l,
safety-celated systems to verify the Design Basis Documbnts (DBDs).
l These walkdowns will be reperformed for all systems '_since the l'
adequacy of the original walkdowns is questionable..The walkdowns will be conducted by a team of representatives from the Nuclear Plant Engineering (NPE), and Plant System Engineering (PSE), and Quality-Assurance.
As part of a new Engineering Excellence' Program, PGE is considering quarterly system walkdowns by PSE-and NPE engineers to provide additional. opportunity to further recognize and evaluate ~ visually apparent problems.
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i PGE pl:.ns to provide written guidanco to personnel prior to
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l conducting the walkdowns. The guidance will focus on recognizing' deficient conditions which could effect the system design basis.
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i Trojan Nuclear Plant Document Control Desk Docket 50-344 October. 27, 1989 License NpF-1 Page 2 of 4 2.
Design Basis Document Program Scope The overall list of DBDs was reviewed by the team for completeness.
The team identified that PGE did not have plans for any generic DBDs, such as Cable and Raceway Systems-or concrete' anchor bolts. As a.
result of this discussion, PGE committed to study and address the need for such Generic DBDs as a. response to the inspection report.
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Response
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PGE has prepared some generic DBDs, specifically for structural and seismic design bases, site external hazards (tornado, external i
flooding,' volcano, aircraft impact, explosion hazaeds, toxic:
chemicals, ship collision with.the intake structure, and freezing weather), and site internal hazards (high-energy and moderate-energy
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'line breaks, flooding due to pipe' breaks, and internally generated missiles).
PGE is in the process of evaluating the entire DBD Program for the
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purpose.of upgrading the program.
All previously issued DBDs will be.
reviewed in 1990 and revised to provide additional. design information as necessary. As a part of this evaluation, PGE,will determine what
. additional DBDs are to be written and plan a schedule for completion
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lof this task. This evaluation will include a study of'the need for i
generic DBDs on Cable and Raceway Systems and Anchor Bolts.1 The-L evaluation is scheduled to be completed by April 30, 1990. A new schedule for additional DBD preparation will then be determined.
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Improper Concrete Anchor Bolt Factor of Safety
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In additien to. the apparent violation for rancrete anchor bolt f actor of safety (Item 50-344/89-09-04), it was 16sntified that there is apparently no design guide, or equivalent oocument, available to establish design requirements for concreto anchor bolts.
PGE committed to include a discussionuof the availability of appropriate i
design guidance such as design manuals or design' guides generally used by designer organizations in response to this inspection report.
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l Trojan Nuclear Plant Document Control Desk
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Docket 50-344 October 27, 1989.
License NPF-l' l
Page 3 of 4 i
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' Response PGE uses design guidance contained in various documents for l
civil / structural designs.
Examples of these documents are:-
- Final Safety Analysis Report (FSAR)
- Re6ulatory Guide-In-House Position Statements
- Civil Structural Desir,n Criteria Standard 11760-C1
- Design Requirements for Original Specifications
- Applicable Codes and Standards-
- Uniform Building Code
- American Institute of Steel Construction (AISC)
- American Iron and Steel Institute (AISI),
- American Concrete' Institute (ACI)
- Amerj ean Welding Society (AWS) l
- Civil Branch Guides t
- Cable Tray Support Analysis.
- Seismic Analysis and Roviews
- Passive Fire Protection Proce6ures The need for additinnal design guidance is recognized. The issuance 1
of additional Civil Branch Guides is planned:with at.least three to be issued prior to the end to 1989.. One of these guides will include more specific design criteria for concrete anchor bolts.
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In a6dition to the Civil Branch cuides, PCE has several existing Design Criteria Documents for both Electrical and Mechanical Branches. These documents are' revised as necessary and new documents
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are issued on an as-needed basis as identified by PCE management.
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- 4. Systematic Efforts to Identify _a_n,_d Resolve Desian Vulnerabilities-l
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PGE was requested to provide written response discussing management plans retarding systematic efforts to identify and resolve design l
vulnerabilities through future Srafety System Functional Inspections
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(SSFIs) or other processes.
Response
In addition to using system-related DBD walkdowns and other processes previously addressed in this attachment, PGE has committed to performing SSFIs at the Trojan Plant.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 October 27, 1989 i
Cicense NPF-1 Page'4 of 4 I
PGE will perform these evaluations under the cognizance of the l-Quality Operations (QO) Branch of the Nuclear Quality Assurance Department. Nembers of the existing QO staff will be supplemented.
l with experienced contract engineers to form an inspection team for the evaluation. The 1989 inspectirn'is' scheduled to begin
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November 13, 1989 and will cover the Service Water System.
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S. Review of Jafety Evaluations The inspector, in discussion with licensee representatives, sus-gested that the procedure for safety evaluations (Procedure 100-5, Revision 4) should be reviewed for improvements and that the licensee might consider reviewing a sample of past safety. evaluations for similar omissions.
The licensee was requested on July 21, 1989,-to' consider these suggestions in their response.to the apparent violation.
Response
Nuclear Division Procedure (NDP) '100-b, " Preparation of Safety Evaluations Required by 10 CFR 50 and Trojan Technical Specifica-tions", was reviewed for improvements, and Revision 5 has been implemented. Revision 5 includes the guidelines from the Nuclear l
l Safety Analysis Center (NSAC).Cuide 125.
Further improcaments are i
currently under evaluation.
PGE has considered the suggestion to conduct a review'of a sample of 5
past safety evaluations.
Since the safety evaluations receive an independent review by the Trojan Nuclear Optrations Board (TNOB) staff, it has been determined that further independent review is unnecessary.
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